Whether the mattress regulation applies to your company does not depend on whether you make mattresses, but on the role you play in the supply chain. Do you sell mattresses under your own brand, import them from outside the EU, or do you buy them as a hotel or care institution for your own use? That makes a difference to the question of whether the obligations surrounding the digital product passport fall to you or to someone else in the chain.
The regulation primarily directs the obligations at the party that places the product on the market: the manufacturer, or whoever takes their place such as an importer or a company that sells under its own name. Whoever only buys for own use, such as a hotel that purchases mattresses for its rooms, is generally not a party that has to create a passport itself. But whoever resells, repackages under their own brand or is the first to place on the market in the EU, may well come into view.
Why the role in the supply chain is decisive
The regulation works with roles, not with business types. A wholesaler that delivers mattresses unchanged to shops has a different position than a wholesaler that puts its own brand on the mattress. A specialist bed retailer that exclusively sells brands from well-known manufacturers generally does not have to draw up a passport itself; that responsibility then lies with the manufacturer or importer who introduced the product. As soon as you arrange your own imports from a country outside the EU, that position changes. Who exactly fulfils which role and what that entails is described in the knowledge base based on the official text; it is worth going through that before you draw conclusions about your own situation. read the roles and concepts carefully
When you as a buyer still need to know something
Even if you do not have to draw up a passport yourself, it may be relevant for your purchasing process that your supplier does. Large purchasing organisations, such as hotel chains or care institutions that procure mattresses in bulk, are increasingly asking for the presence of a product passport as part of the purchasing conditions, even though the legal obligation does not yet apply to every link in the chain. That is not a legal requirement on the buyer itself, but a practical way to ensure that the information the regulation will require is actually available when needed. Whoever includes that in supplier contracts now avoids having to sort out the question later under time pressure.
The difference between reselling and placing on the market
A common assumption is that only the manufacturer can be responsible. That is not always correct. Whoever sells a mattress under their own name or brand, even if that mattress is manufactured elsewhere, can according to the regulation be seen as the party placing the product on the market. The same applies to companies that assemble mattresses from parts from different suppliers and offer the end result as their own product. In those cases, responsibility for the passport shifts to you, even if you describe yourself primarily as a reseller.
What this means in practice
For most bed specialty retailers selling established brands, little will basically change: the supplier will then provide the data and QR data carrier, and the shop only needs to pass them on to the customer. For companies that import themselves, offer private label products or assemble mattresses, it is different. In those cases, it is advisable to map out early which data is already available and which is still missing, so that no rush arises once the obligation actually takes effect. The expected date for this is not yet fixed; the delegated act that must regulate this is expected to be published in the second half of this decade, and this page will be updated as soon as that date is known.
Assess your own situation
Because the role your company plays is decisive, it is difficult to say in general whether the regulation applies to you. A quick self-check can quickly clarify which direction you should be thinking. get an indication of your situation in a few questions provides a first picture, without you needing an account right away. For those who want to know more about how that indication is arrived at and which sources are used, there is an explanation of the methodology. read how the information is compiled
Whether the regulation applies precisely to your company and which steps are involved is ultimately a question that differs per situation and which a lawyer or the competent supervisory authority can best answer. If you want to get a picture yourself first before taking that step, the knowledge bank is a logical starting point, along with the frequently asked questions for the points that come up most often. read the most frequently asked questions